ML20137T243

Responds to Re Comments Concerning Human Performance Program Plan.Conclusions & Recommendations & Staff Responses Encl

ML20137T243
Person / Time
Issue date:	04/10/1997
From:	Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Seale R Advisory Committee on Reactor Safeguards
References
ACRS-GENERAL, NUDOCS 9704160040
Download: ML20137T243 (9)

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%, *****$ April 10, 1997 Dr. Robert L. Seale, Chairman Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

HUMAN PERFORMANCE PROGRAM PLAN This responds to your letter dated February 13,1997, in which you provided comments concerning the Human Performance Program Plan. Your conclusions and recommendations and the staff's responses to each are enclosed.

Sincerely, 4

L. o ep allan Ex utive Director for Operations

Enclosure:

As stated cc: Chairman Jackson Commissioner Rogers lf ji Commissioner Dicus Commissioner Diaz h

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April 10, 1997 Dr. Robert L. Seale, Chairman Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

HUMAN PERFORMANCE PROGRAM PLAN This responds to your letter dated February 13,1997, in which you provided 1

comments concerning the Human Performance Program Plan. Your conclusions and recommendations and the staff's responses to each are enclosed.  !

i Sincerely, Original Signed by L.J. Callan L. Joseph Callan Executive Director 1 for Operations 1

Enclosure:

As stated l cc: Chairman Jackson  !

Commissioner Rogers Commissioner Dicus Commissioner Diaz Commissioner McGaffigan SECY OGC Distribution:

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Enclosur.g Responses to ACRS' Conclusions and Recommendations

1. The HPPP is not a plan. It is, instead, an inventory of human performance projects within the agency. The HPPP should state explicitly what its goals are, what research efforts will be required to achieve these goals, and when and how it will be known that they have been achieved. The ownership of the present plan is diffuse.

The success of such a plan as well as its dynamic nature require that ownership of the entire plan be clearly assigned.

The ACRS is quite curect. As stated in our February 4,1997, responses to ACRS questions, the HPPP was intended to function as a mechanism to coordinate human factors activities among the Agency's offices. However, we agree that a comprehensive program plan needs to be developed.

I Presently, ownership for coordination for the HPPP is in NRR. Since future needed efforts  !

are developmental and are expected to involve comfirmatory research, leadership will be shifted to the Office of Nuclear Regulatory Research. An agency-wide program plan for i

human reliability assessment and human performance evaluation is expected to be developed for review by the end of June.

1 I

2. A well-planned research effort in human performance is urgently needed to support both the regulation of plant operations and the transition to risk-informed and performance-based regulation. The overall perspective that can be provided by high-level models of human performance would be helpful in the planning of this research effort. A number of such models are reviewed in NUREG/CR-6350.

We agree that a comprehensive research plan is needed. Consistent with the ACRS's suggestion, the staff is developing a plan for integrating activities in human reliability assessment and human performance evaluation. Beyond providing a mechanism for coordinating current staff activities in these areas, the plan will articulate the conceptual relationships between human reliability analysis activities and those of human performance evaluation. In addition, the "ATHEANA" model, which was developed to improve human reliability analysis, will serve as the framework to guide activities associated with this initiative.

The essential elements of the plan will be a statement of the mission of the human reliability assessment and human performance evaluation initiative in the Agency, a definition of strategies for achieving the mission, and the identification of program areas established to implement the strategies. Within each program area, summaries of ongoing and planned activities will describe their relevance and consistency with the defined j mission, strategies, and programs. Such an approach to planning is expected to better highlight any redundancy, gaps, and disproportionate emphasis in current and proposed '

staff efforts. We will brief the ACRS on the program plan after it is fully developed.

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3. The development of indicators of a good safety culture, the design of a meaningful human performance reporting system, and the impact of downsizing and deregulation on human performance should be major elements of the research effort.

We agree that the research effort should include development of indicators of good safety culture, identification of the impact of downsizing and deregulation on human performance, J

and the design of a meaningful human performance reporting systern.

As part of its planned program to develop the technical basis and guidance on management and organizational influences in human performance and plant risk, the influences of a

management practices and safety culture on human performance and human reliability will be identified. Additionally, the impact of downsizing and deregulation on human perfum.ance and human reliability will be investigated. As part of efforts to improve the Senior Management Meeting process, the staff is identifying measures of economic stress that can be used to identify plants for increased safety monitoring.

Licensees are required to report data to the NRC on factors that influence operating events, including factors that contribute to human performance during events. However, the human performance data collected are not always sufficiently detailed to provide the basis for formulating research or regulatory programs. As part of its planned program to conduct operating events analysis to support human performance evaluation and human reliability analysis, the staff expects to recommend reporting requirements to better support HRA and human performance evaluation and to modify the LER coding scheme to include more human performence information.

Dr. Robert L. Seele, Chairman Advisory C mittee on Reactor Safeguards U.S. Nuclear gulatory Commission

Washington, D. 20555

Dear Dr. Seale:

This responds o your letter dated February 13,1997,in which you provided comments concerning Human Performance Program Plan. Your conclusions and i; ,

recommendations and the taff's res' ponses to each are enclose'd.' 4

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1 Dr. Robert L. Seale, Chairman .

Advisory Committee on Reactor Safeguards i U.S. Nuclear Regulatory Commission i Washington, D.C. 20555

Dear Dr. Seale:

This responds to your letter dated February 13,1997, in which you provided I comments concerning the Human Performance Program Plan. Your conclusions and recommendations and the staff's responses to each are enclosed.

Sincerely, L. Joseph Callan  !

Executive Director i for Operations

Enclosure:

As stated cc: Chairman Jackson Commissioner Rogers Commissioner Dicus Commissioner Diaz Commissioner McGaffigan SECY Distribution:

Docket File w/ encl SCollins Dross, AEOD PUBLIC w/enci JBlaha RZimmerman LCallan DMorrison, RES WHodges CPaperiello, NMSS AThadani FCoffman JMitchell KCyr, OGC TMartin JPersensky ACRS File HHFB RF NRR Mailroom GT#G970104 EDO Mailroom GT#G970104 Document Name: G:\OTHERS\ACRSLTR. MAR T. . or se > w w a. 6= c - cm .m =mw r - cm .m =w ao-,. x - x.

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_ Dr. Robert L. Seale, Chairman Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Commission j

{ Washington, D.C. 20555 I

Dear Dr. Seale:

l This responds to your letter dated February 13,1997, in which you provided comments concerning the !1uman Performance Program Plan. Your conclusions and recommendations and the staff's responses to each are enclosed.

Sincerely, '

L. Joseph Callan l Executive Director for Operations  ;

1

Enclosure:

As stated cc: - Chairman Jackson Commissioner Rogers Commissioner Dieus Commissioner Diaz Commissioner McGaffigan SECY.

' Distnbution:

Docket File w/ encl SCollins Dross, AEOD PUBLIC w/enci JBlaha RZimmerman LCallan DMorrison, RES .WHodges CPaperiello, NMSS AThadani FCoffman JMitchell KCyr, OGC TMartin JPersensky ACRS File HHFB RF NRR Mailroom GT#G970104 EDO Mailroom GT*G970104 Document Name: G:\OTHERS\ACRSLTR. MAR Ts & a osyy of he doomsment, indkass in ein box 'C' = Cayy winsoms hiancanswo 'E' = Copy we smachimams/ , * = No copy OFFICE HHFB/DRCH DRCH l ADT 'NRR l AEOD lE - RJig/gh EDO l NAfAE CThomas:sc BBoger:eb AThadani . SCollins ORessE.Rg Ofportfson LCallan DATE / /97 / /97 / /97 / /97 03/28/97GJf/31/97 / /97 0FFICIAL RECORD COPY

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ACTION EDO Principal Correspondence Control FROMs DUE: 03/13/97 EDO CONTROL: G970104

//#/ 97 DOC DT: 02/13/97 FINAL REPLY:

'R. L. Seale, ACRS TOs Chairman Jackson <

FOR SIGNATURE OF : ** GRN ** CRC NO:

Executive Director DESCr ROUTING:

HUMAN PERFORMANCE PROGRAM PLAN (HPPP) Thompson Jordan Norry Blaha Morrison, RES Paperiello NMSS DATE: T2/14/97 Ross, AEOD Caputo, OI ASSIGNED TO: CONTACT: Cyr, OGC Mitchell, OEDO NRR Miraglia ACRS File SPECIAL INSTRUCTIONS OR REMARKS:

Prepare response to ACRS for EDO signature. Add Commissichers and SECY as cc's (shown on original for reply).

USE SUBJECT LINE IN RESPONSE.

NRR RECEIVED: FEBRUARY 18, 1997 NRR ACTION: DRCH:B0GER' - - - -

NRR ROUTING: COLLINS ACTION MIRAGLIA ""

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ZIMMERMAN , DUE TO NRR D! RECTOR'S OF.i!.

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I February 13, 1997 i

The Honorable Shirley Ann Jackson Chairman l U.S. Nuclear Regulatory Commission l Washington, D.C. 20555-0001 I

SUBJECT:

HUMAN PERFORMANCE PROGRAM PLAN

'During the 438th meeting of the Advisory Committee on Reactor l Safeguards, February 6-8, 1997, we completed our review of the NRC activities identified in the Human Performance Program Plan (HPPP) .

Our Subcommittee on Human Factors met on September 20 and December 3, 1996, to review these activities. During these reviews, we had the benefit of discussions with representatives of the staff.

In your remarks of December 2, 1996, to all NRC employees, you stated:

l As we move to an era of nuclear power industry restructuring and declining NRC and industry resources, it is imperative that we are able to diagnose potentially declining licensee performance as early as possible.

We agree with your assessment. We believe that an appropriate HPPP would contribute significantly to the development of such diagnostic tools.

conclusions and Recommendations

1. The HPPP is not a plan. It is, instead, an inventory of human performance projects within the agency. The HPPP should state explicitly what its goals are, what research efforts will be required to achieve these goals, and when and how it will be known that they have been achieved. The ownership of the present plan is diffuse. The success of such a plan as well as its dynamic nature require that ownership of the entire plan be clearly assigned.

2. A well-planned research effort in human performance is urgently needed to support both the regulation of plant operations and the transition to risk-informed and

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performance-based regulation. The overall perspective that can be provided by high-level models of human performance would be helpful in the planning of this research effort. A number of such models are reviewed in NUREG/CR-6350,

3. The development of indicators of a good safety culture, the design of a meaningful human performance reporting system, and the impact of downsizing and deregulation on human performance should be major elements of the research effort.

Discussion Operational experience has shown that human performance is a major factor in the safe operation of nuclear power plants.

Understanding what can go wrong at a plant requires an integrated evaluation of both hardware and human performance; i.e., the plant must be viewed as a sociatechnical system. In particular, the term

" human error," which carries the implication that the operators are to be blamed, is inaccurate in many instances and one must investigate and understand the context within which plant personnel function. This context is determined by both the design and the physical conditions of the plant, as well as by the prevailing safety culture.

The development of a plan for research on human factors is certainly not a simple task. This task would be made easier and the recommendations more convincing if the task were guided by a high-level model that identifies the important elements that

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influence the likelihood of unsafe human acts. Various models and taxonomies have been proposed in the literature and some are beginning to receive wide acceptance. Human performance models and error classifications that could be suitable guides for developing a research plan are being used in other projects in the Office of Nuclear Regulatory Research. The models discussed in NUREG/CR-6350, along with insights from operational experience, could serve to guide the development of an HPPP.

One specific element we would like to see addressed in the HPPP is

the impact of situational assessment on compliance with procedures.

Investigations of actual incidents and simulator exercises from nuclear and other industries have demonstrated the importance of what Professor James Reason of the University of Manchester calls

" intended violations" (circumventions) of procedures by plant personnel. The researchers who collected data from simulator exercises point out that these were not necessarily errors; the operators simply did what they felt was the optimal response to the evolving accident. We believe there is a need to understand the reasons for such deviations and how training, procedures, and the plant safety culture could be modified to eliminate

" circumventions" to the extent possible.

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i The present HPPP contains elements that are worth pursuing. Other elements that should be contained in the HPPP include activities to t gain a better understanding of the concept of safety culture and to }

develop indicators of a good safety culture. The human reliability i

analysis research project should 11so be part o'f the HPPP. We will  !

continue to work with the staff in developing an effective HPPP.

i  !

, sincerely, .

! R. L. Seale Chairman i s

References:

- I i 1. Memorandum dated July 31, 1996, from Cecil Thomas, Office of i

Nuclear Reactor Regulation, to John Larkins, ACRS Executive j Director,

Subject:

Forwarding Human Performance Plan Rev. 1

2. Office for Analysis and Evaluation of Operational Data Report j E-95-01, " Operating Events with Inappropriate Bypass or Defeat 4 of Engineered Safety Features," July 1995  :

3. U. S. Nuclear Regulatory Commission, NUREG/CR-6093, "An j

Analysis of Operational Experience During LP&S and a Plan for l Addressing Human Reliability Issues," June 1994 U. S. Commission,

4. Nuclear Regulatory NUREG/CR-6265, "Multidisciplinary Framework for Analyzing Errors of Commission and Dependencies in Human Reliability Analysis,"

August 1995

5. U. S. Nuclear Regulatory Commission, NUREG/CR-6350, "A

. Technique for Human Error' Analysis (ATHEANA)," May 1996

6. Reason, J.T., Human Error, Cambridge University Press, i Cambridge, United Kingdom, 1990 i 7. R. Montmayeul, F. Mosneron-Dupin, and M. Llory, "The Managerial Dilemma between the Prescribed Task and the Real l Activity of Operators: Some Trends for Research on Human

. Factors," Reliability Enaineerina and System Safety, 45:67-73, 1994 i 8. U. S. Nuclear Regulatory Commission, NUREG/CR-6208, "An i

Empirical Investigation of Operator Performance in Cognitively

Demanding Simulated Emergencies," July 1994

9. International Atomic Energy Agency, Vienna, International l'

Nuclear Safety Advisory Group, " Safety Culture," Report 75-INSAG-4, 1991 1 10. NRC Chairman Shirley Ann Jackson's remarks to all NRC ]

j employees, December 2, 1996 1 l l 6

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